January 04, 2010

A Quick Look Toward 2010

Posted by Anthony Demangone

When I was a young lad, I realized that I would graduate from high school in 1990. 1990! That date seemed like something from a science fiction movie. Twenty years later, I still get those same feelings each year. 2010? It can't be. But it is. And it will take me about a month to remember to write 2010 on my checks.

With that in mind, here's a quick run-down on things that we should keep in mind this year.

SAFE Act. If you are a state or federally-chartered credit union, there's still no news here. NCUA has yet to issue a final rule. And the deadline for registration is still 180 days after the system starts accepting registrations.

Escrowing. I'm not even sure if that is a valid verb. But we'll start doing that for higher-priced mortgage loans this April. And for manufactured homes, the escrow deadline is in October.

BSA. The BSA manual will be updated at some point. I'm not sure when, but it very well may require you to tweak your BSA/AML program. The CARD Act will require Treasury to issue rules to bring stored value cards under the BSA regulatory system. I expect that rule at some point.

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